| Action Date |
Action |
Description |
DEC Staff |
| 2/28/1993 |
Update or Other Action |
Preliminary Assessment conducted by E&E, Inc. staff with the Corps of Engineers representative on October 5, through October 8, 1992 for Saint Paul and Saint George Islands. The PA did not present extensive or complete site characterization, contaminant fate determination, qualitative or quantitative risk assessment or discussion regarding sites' aesthetics. During each site visit, a photoionization detector (PID) was used to determine if potential source areas were emitting organic vapors (OV).
Records show two USTs are located at the gas station: a 1,000 gallon steel gasoline tank UST Number 3 and a 1,000 gallon steel diesel tank UST Number 4. Gasoline UST was reportedly installed in the 70s. The diesel UST is currently not in use and may be empty. Fill and vent pipes were observed for the gas UST but not the diesel UST. It is unknown if the diesel UST was ever removed. The tanks are over 15 years old and do not meet ADEC or U.S. EPA requirements for leak detection, corrosion protection, and spill/overfill protection. It has been recommended that the tanks and piping be replaced. A 1990 site investigation noted that stained soil was evident around the gas station USTs (Buckel 1990). Recommendation: determine the nature and extent of POL and lead contamination. |
Jennifer Roberts |
| 8/11/1994 |
Update or Other Action |
ADEC S. Mawson sent letter to Sharon Lundin NOAA regarding the Former NMFS facilities on Saint George Island. ADEC traveled with NOAA, their consultant, Tanaq Corp. and City of Saint George and their consultant to jointly identify all of the known sites which must be evaluated for remediation in order for Department of Commerce, on behalf of the Federal Government, to comply with State of Alaska statutes and regulations. We also agreed in principal on a sampling protocol. NOAA staff appeared unaware that heating fuel spills associated with underground storage tanks (USTs) were the responsibility of the Federal Government in spite of the fact that the tanks were installed by the Federal Government. Additionally, the fuel used to fill the tanks was owned by the Federal Government and the Federal Government used the tanks during the course of the Federal Government managed fur seal harvest. Our regulations are clear about responsibility for fuel spills.
NOAA staff were also unaware of their responsibility for waste debris. Some of that debris includes vehicles that were brought to Saint George from Amchitka Island, the site of an underground thermonuclear detonation in the 1970s. Our law is also clear about responsibility for these materials. That responsibility remains with the Federal Government.
One other outstanding issue was the condition of the drum dump that is buried in the elementary school playground. NOAA staff disputed the claims of residents that the site has been used for waste disposal and suggested that drums have been carefully placed for slope stability. Although the site had been covered forty years ago, one drum was uncovered (through 4 test holes) that was clearly labeled to have leaded gasoline and the owner's name was the U.S. Fish and Wildlife Service. There was evidence that some of the drums were laid out in an orderly manner, although disposal or use of the drums in this way by the Federal Government is unacceptable.
The last test hole at the elementary school, however, confirmed that refuse had indeed been buried at this site. Among other items excavated was a test tube, similar to those used for blood samples, indicating that medical waste may also have been disposed of in this dump. The presence of this buried refuse and the possible biohazards associated with it are particularly disturbing in an elementary school playground. ADEC is awaiting NOAA's formal response to the July 20, 1994 Notice of Violation letter and if that response conforms to the commitments made on Saint George, then it should be satisfactory. |
Simon Mawson |
| 8/19/1994 |
Update or Other Action |
Letter from NOAA WASC to Janice Adair regarding former National Marine Fisheries Service Facility, Saint George Island response to July 20, 1994 NOV Letter. 1) Name and Agency affiliation of the person answering. Sharon L. Lundin, Chief, Facilities and Logistics Division, Western Administrative Support Center (WASC), Seattle Washington. WASC is a field component of NOAA's Office of Administration, which provides administrative services to Department of Commerce offices located in 10 western states, Alaska, Hawaii, and the Trust Territories. This office is undertaking cleanup on the Pribilof Islands on behalf of NOAA's National Marine Fisheries Service (NMFS).
2) Copies of all written material describing known spills or releases, or stored hazardous substances or solid waste disposal areas at the site, and a description of corrective measures that were taken. Information on any suspected releases which may have occurred or are occurring. To NOAA's knowledge, there is no historical written material addressing these topics. Sharon Lundin and her staff have reviewed to date many thousands of pages of archived material on operations on Saint George Island, including daily logs of the Island Manager and have found nothing at all. All of these materials were written prior to 1984. We are continuing to search for additional records.
Current records, generated through this office, include February 1993 Preliminary Assessment (PA) covering both islands, Woodward-Clyde March 31, 1994 Phase 1B Environmental Assessment Report done after the drum cleanup work last year (1993), which ADEC indicated to have reviewed. NOAA enclosed an additional copy of the PA. It should be noted that few new sites, identified the first week of August by the village residents, are not reflected in these reports.
3) History of land uses on the property, nature of past present federal operations, any actions that may have caused a release or threat of release of hazardous substances. Describe the physical characteristics of current or former federal facilities including major structures, water wells, fuel or waste storage systems, drainage systems, and solid waste disposal areas.
Attachment A is a summary of Pribilof history and NMFS operations. A copy of the document nominating both Islands as a National Historical Preservation District is included, which gives information on the major structures. A map identifying water wells and solid waste disposal areas insofar as we know them is included in the PA. NOAA does not have the as-builts of any structures on Saint George, or of underground piping systems. It has recently come to NOAA's attention that Indian Health Service may have some additional information about the wells and landfill; we have not had the staff resources necessary to research this yet.
During a August 2-4, 1994 site visit, NOAA, City of Saint George, ADEC came to a consensus on a comprehensive sampling plan for all sites on the Island including a few new sites recently identified by residents. As soon as it is finalized and approved by ADEC, NOAA will do the sampling in mid-late September 1994. One of the new sites identified was PCB-filled transformers located next to the schoolyard. NOAA will be removing them and disposing of the wastes in the same time period that sampling is conducted, when NOAA has staff on the island. |
Janice Adair |
| 3/30/1995 |
Update or Other Action |
Woodward Clyde Phase 1B Environmental Assessment a.k.a. Expanded site (inspection) investigation received which was to identify the nature and extent of soil and groundwater contamination. The data obtained from the site inspection were used to determine which areas have contaminated media and need further investigation. Test pits TP-3, TP-4, and TP-5 were sampled for this site. TP-3 had a surface sample with DRO at 1,500 mg/kg, xylenes 5.8 mg/kg. A subsurface sample taken at 6.5' below ground surface had xylene at 35 mg/kg. TP-5 collected at 5' below ground surface had DRO at 17,000 mg/kg, GRO at 1,600 mg/kg and ethylbenzene at 5.3 mg/kg and xylenes at 14 mg/kg. The recommendations were to remove the underground storage tanks from the site. |
Ray Dronenburg |
| 6/1/1995 |
Site Added to Database |
DRO, GRO and xylenes. |
Ray Dronenburg |
| 8/2/1995 |
Preliminary Assessment Approved |
(Old R:Base Action Code = SA2R - Phase II SA Review (CS)). Approved an Environmental Site Assessment. |
Ray Dronenburg |
| 5/6/1996 |
Site Ranked Using the AHRM |
Initial ranking by Shannon and Wilson. |
S&W |
| 10/31/1996 |
Cleanup Plan Approved |
Ray Dronenburg sent Polarconsult Inc. Dave Ausman, a contractor working on behalf of NOAA, an approval letter for containment cell design. Fax was received on 10/30/1996 for approval for a contaminated material storage cell. Unfortunately the fax copy was not clear enough to determine exact specifications, however, it is assumed (by ADEC) that ADEC guidance documents regarding contaminated material storage were considered in the design. (Plan states: "Since the containment cell will incorporate a water treatment system and regular maintenance program to process accumulating precipitation, Tanaq requests that the department waive the requirement for a top cover for the soil. The main reason for this request is that the top cover is expected to be problematic given the island's high winds and the need to uncover the piles on a daily basis."
ADEC's primary concern for the storage facility will be the protection of any surface water or groundwater sources. Having been to St. George on several occasions it would appear that the site selection would be near or on the old runway and not in the vicinity of any surface water sources, however, because of our discussion regarding cover for the stockpile and with a potential for leachate from the pile as well as rinsate from the UST activities, it might be prudent to develop at some point, a schedule for monitoring for excessive water accumulation.
The cell design and location are approved as submitted.
NOTE to file: Petroleum contaminated soils were from UST and Non-UST related sources encountered during FY97 Phase I Cooperative Agreement a.k.a. "Part I of the cleanup operations" on St. George Island. These include, but are not limited to, TPA 02 STG Former Drum Storage Area and TPA 03 Inactive Gas Station (oceanfront) (1624 cubic yards removed), TPA 10 STG Former Kerosene Drum/AST Storage Area, TPA 11 STG Cottage C UST (98 cubic yards removed), TPA 12 STG Former Hangar Building (195 cubic yards removed), TPA 21 Abandoned City Diesel Tank Disposal Site (1500 cubic yards removed), and TPA 23 Inactive/Abandoned Diesel Tank Farm (4,146 cubic yards removed.). |
Ray Dronenburg |
| 7/17/1997 |
Update or Other Action |
Memorandum to M. Goetz Project Mgr. NOAA. RE: Permits for water discharge. 7/16/1997 Robert Dolan who handles permit system for discharge of wastewater suggested that rather than issue a specific permit for the discharge of waters from the stockpile site on St. George, he would approve Contaminated Sites staff handling the situation. Dave Ausman will add couple of pages to his monthly report to include: on a monthly basis, report the gallons of water collected from the stockpile berm and placed into the 20,000 gallon tank. Prior to any discharge, Polarconsult will then take batch samples to ensure that maximum contaminant levels (MCLs) for wastewater are not exceeded and then using the St. George sewage truck, move the water to the sewage outfall.
Lastly, Polarconsult will post a lookout to ensure that "sheen" does not occur. The only other alternative would be additional paper work (permitting process) to achieve the same results. Mr. Ausman is faxing Ray Dronenburg in a memorandum of understanding for the procedure and when the Department receives it will provide NOAA with a copy. The Department does not see any reason not to do the same thing on St. Paul.
7/17/1997 FAX Polarconsult to R. Dronenburg: Discharge of water from the soil containment cell. Water will be collected in the 20,000 gallon tank adjacent to the cell, batch analyzed, and transferred to the City of St. George's sewer system. The system is connected to an outfall line which discharges to the Bering Sea. The sample collection, analysis, record keeping, effluent limitations, and noncompliance notification will be performed in accordance with the procedures outlined in the ADEC waste water general permit #9240-DB005. In consideration of the mixing zone allowance, the effluent limitation will be 1 mg/L for Total Aromatic Hydrocarbons (EPA 602) and 1.5 mg/L for Total Aqueous Hydrocarbons (EPA 602+610) as allowed in appendix 1.B of the permit. The city of St. George has agreed to the discharge of water through the local sewer system provided ADEC indicates approval.
Signed and approved by Ray Dronenburg July 17, 1997. |
Ray Dronenburg |
| 8/29/1997 |
Update or Other Action |
In July and August 1997, NOAA's contractor, the St. George Tanaq Corporation (Tanaq), and its subcontractor, Polarconsult Alaska Inc. (Polarconsult), removed the two 1,000-gallon USTs from TPA Site 3. Inspection of the tanks and assoicated piping indicated that, although the tanks were in operable condition, the various piping connections were improperly made and probably contributed to constant leakage of diesel fuel and gasoline when in use. As a result, Tanaq and Polarconsult removed the fueling shack, dispensing station, and approximately 1,624 cubic yards of contaminated soil from the site.
Removal of contaminated soils from around the UST locations continued until sample results indicated cleanup levels had been met, equipment refusal was reached, or it was determined that further digging might undermine the municipal sewer system on the north side of the excavation. Samples taken to direct soil removal and document final contamination levels indicated that although most of the contamination associated with the site was removed, some was left in place at the bottom of the excavation and in the vicinity of the municipal sewer system. |
Ray Dronenburg |
| 2/27/1998 |
Document, Report, or Work plan Review - other |
Letter to Minh Trinh RE: UST Site closure reports. Site 3 Gas Station #2 Facility ID 3047 tanks 3 and 4. Two (2) 1,000 gallon USTs containing gasoline and diesel fuel were removed and assessed during July and August 1997. Contamination remains in the soil at levels exceeding the target cleanup levels: one sample SS035, contained lead at 248 mg/kg, GRO ranged from non-detect to 768 mg/kg, benzene ranged from non-detect to 3.2 mg/kg, total BTEX ranged from non-detect to 193 mg/kg and DRO ranged from non-detect to 2,430 mg/kg. The data collected from the excavation, combined with the fact that the locations were surveyed will simplify the next phase of investigation and corrective action. Additional investigation and corrective action will be necessary for this site. |
Lynne Bush |
| 6/24/1998 |
Update or Other Action |
R. Dronenburg letter w/L. Bush letter attached to Mr. Minh Trinh Pribilof Project Manager re: Contaminated Sites (LUST) stockpile St. George Island. On several occasions the Department has requested NOAA provide some sort of contractual assurance that leachate from the stockpile would be handled consistent with an earlier agreement. This assurance has never been achieved. Additionally and since the original agreement, extensive community concerns have been expressed for contamination spreading as caused by blowing material from the exposed stockpile, a concern the Department supports.
Please note that Ms. Bush has requested a thirty (30) day time frame be allowed for this action. The Department is aware that negotiations for the planned Phase II portion of this cleanup action has suffered considerable delay and therefore considers immediate cover as essential.
While the work plan detailing the construction of the stockpile was originally approved without a cover, it became apparent that a cover would be necessary to protect human health and the environment. After discussion of site conditions during a visit by Bush in March 1997, Mary Goetz, then Program Manager for this project, agreed to Bush's request to cover the stockpile. As of today, the stockpile has yet to be properly covered. On June 17, 1998, Department staff observed the stockpiled soil from the site not covered and has reportedly not been covered since the stockpile was created. Photos are enclosed of the stockpile not being covered.
The Department requests NOAA: cover the entire stockpile in accordance with 18 AAC 78.311 within thirty (30) days of receipt of this letter and provide written statement to the Department within thirty (30) days of receipt of this letter documenting the stockpile has been covered. Please be aware that the Department may request sampling for secondary contamination in the areas under and around the improperly contained stockpile. Further, the Department may require calculations of air emissions and evaluation of the potential impact to human health and the environment. Evaluation of the potential impact to the seal haul-out located in close proximity to the stockpile may be required, as well.
The leachate collection system, designed and installed prior to the Department's request that the stockpile be covered, also does not appear to be in good working order. Please revise the existing workplan or submit a new workplan to the Department for review and approval, to include any needed repairs, replacement, long term maintenance, or decommissioning of the system, whichever is more appropriate to your long term plans for the stockpile. Include a schedule with your statement of proper containment that details the timetable for remediation and disposal of the soil contained in the stockpile.
*June 28, 1998 NOAA sent Photos to R. Dronenburg with letter stating stockpile has been properly covered and contained. |
Ray Dronenburg |
| 11/12/1998 |
Update or Other Action |
Site Number 3 OU 4 update for TPA. Regulated USTs (1 each, 1,000 gallon gasoline, 1 each, 1,000 gallon diesel) removed, attached underground diesel supply pipeline removed but not investigated, pump island removed, station building demolished, 1,624 cubic yards of PCS was excavated and stockpiled with the excavation backfilled with clean fill. Phase I Final Debris removal report due February 1999. Phase II Draft work plan due March 29, 1999. Phase II draft work plan due March 29, 1999. Final work plan due April 26, 1999. Phase II will require residual debris removal, PCS remediation, confirmation sampling and analyses, site assessment, and site restoration. Monthly progress reports to ADEC after project award until site closure.
Flow chart attached for confirmation sampling and applicable to all TPA sites. Definition of a site assessment attached also and is applicable to all TPA sites. Site restoration is defined as one or more of the following actions dependent on each TPA site, existing site use, and intended post restoration use: Recontouring, regrading, soil or scoria addition or removal, wind/water erosion control, and revegetation. |
Ray Dronenburg |
| 9/10/1999 |
Update or Other Action |
Letter from Jennifer Roberts which states that ADEC is halting further accrual of stipulated penalties against NOAA for failure to fulfill and meet the requirements of the Pribilof Islands Environmental Restoration Agreement in 1998 and part of calendar year 1999. |
Jennifer Roberts |
| 11/15/1999 |
Update or Other Action |
NOAA John Lindsay Pribilof Project Office (PPO) sent letter to Louis Howard. Subject: Inability to Install St. George Petroleum Stockpile Cover This letter is a follow-up to a mutual decision between NOAA and ADEC made on St. George Island on 28 October 1999 to forego further attempts to install the petroleum contaminated soils stockpile cover. This decision was made during discussions between you, Ms. Laura Ogar of the Solid Waste Program and me. The following chronology represents the sequence of events leading to the timing of the installation with the subsequent encounter with the foul weather season, the primary basis for this decision.
On 31 July, NOAA received a letter dated 26 July from ADEC requesting that the PCS stockpiles on St. Paul and St. George be covered according to Alaska regulations. NOAA notified the Navy Engineering Facilities Activity (EFA) and Navy Supervisor of Shipbuilding (SupShip), Environmental Detachment (DET) to begin planning for cover installation on the Pribilofs.
On 9 August, NOAA received a stockpile cover design and estimated cost of installation from SupShip. The PPO had requested the NOAA to authorize Supship funds to implement the cleanup actions on 20 May 1999. Internal approval was received on 7 June. But because the fund transfer exceeded $1 million, additional approval was required at the Department of Commerce level. This approval did not come until 8 September. However on 18 August, the SupShip Contracts Administrator refused to allow the DET to accept any additional work as DET was privatizing in mid-September 1999 as part of the Navy’s downsizing. However, with residuals from an initial $50,000 fund transfer to DET in June, DET proceeded with the procurement of the cover material for use by whoever could complete the installation. On 23 August, ADEC provided me a copy of its comments on the St. George stockpile cover design with tacit approval to proceed. On 25 August, ADEC gave final approval on the cover design.
The PPO attempted to utilize the services of EFA for placement of stockpile covers on both St. George and St. Paul, but the PPO was limited to transferring funds not to exceed $100,000 without MOU signoff. The $100,000 transfer to EFA was authorized but it was sufficient to allow for the covering of only the St. Paul Blubber Dump stockpile.
Consequently, the PPO had to seek an alternative contractor.
On 8 September, the PPO inquired about other contractor avenues available to it for the stockpile cover installation, and began preparations on a Scope of Work and Independent Government Estimate. On 16 September, NOAA requested a technical and cost proposal from Tetra Tech EMI to cover the St. George stockpile. On 14 October, NOAA contracting gives Tetra Tech EMI verbal authorization to proceed with the St. George stockpile cover installation. On 15 October, a barge delivers the cover material purchased by DET to St. George. TTEMI concludes negotiations with its subcontractor Tanaq Corporation, and on 26 October, TTEMI arrives on St. George to install the cover. During the night of 27 October, an unforecasted snowstorm covers the stockpile and high winds make it impractical and unsafe to attempt to install the cover. Seasonably adverse weather has set in and NOAA and ADEC jointly agree that it is not pragmatic to expect to cover the stockpile this season. Not only do strong winds compromise safety to workers laying down the cover, trenching for the berm around the perimeter threatened to damage the stockpile liner which was snow covered. NOAA intends to treat the stockpile at the commencement of the next field season. On 16 November, NOAA, some of its contractors and Tanaq Corporation are visiting with a vendor of a heat treatment system to discuss the technical and cost effectiveness of its application at the beginning of the next field season. NOAA believes the above information and efforts should be sufficient to satisfy pertinent requirements ADEC has identified for halting the accrual of stipulated penalties under the Two Party Agreement. |
Louis Howard |
| 12/10/1999 |
Update or Other Action |
Revised site schedules received to prevent recurring stipulated penalties. Site characterization to be conducted in 2000 (contractor to mobilize by August 2000). |
Louis Howard |
| 5/30/2000 |
Update or Other Action |
In spring 2000, the ETC Operations Area was constructed under a NOAA cooperative agreement with Tanaq. With this addition, the total area encompassed became 2.54 acres with a footprint of approximately 560 feet long by 190 feet wide (Figure 3). Included within this area were the PCS stockpile and the ETC Operations area, along with a 15,000 gallon aboveground storage tank (AST) for storing leachate pumped from the stockpile sump collection system, a turn-out area, a 4,000 gallon AST to provide diesel to the ETC system, a 1,200 gallon AST to provide diesel to the 50KW generator at the ETC site, two 20 feet long intermodal transport containers (conexes) to provide storage at the ETC site, and a laydown area for open storage of ETC stainless steel shell and mild steel piping, piping manifolds and base frames. |
Louis Howard |
| 9/30/2000 |
Update or Other Action |
In June and August 2000, Columbia Environmental Sciences Inc. (CESI) conducted site reconnaissance activities for several sites on St. George Island (including TPA 03). CESI noted that the ground had been extensively reworked and covered with scoria; there was no obvious staining. |
Louis Howard |
| 4/11/2001 |
Update or Other Action |
Staff sent NOAA comment letter on TPA 2001 proposed schedules. These proposed revisions to Attachment B of the Pribilof Islands Environmental Restoration Agreement (TPA) are being reviewed under the Modification clause (section 82) of the TPA. Section 82 provides “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B may be effected by the agreement of the Project Managers.”
ADEC approves the new schedule with two exceptions: 1) the schedule for the sites which NOAA has identified as “formerly used defense sites” (FUDS) and, 2) the schedule does not include projected work for many of the sites in calendar year 2002 and beyond.
1) FUDS. With respect to the sites that NOAA has identified as FUDS sites, ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act). In order make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
2) Long-term schedule beyond calendar year 2001. NOAA’s cover letter accompanying the Project Schedules states that “while a limited number of the schedules go into calendar year 2002, most are not projected beyond 2001 because of the near constant shifting of priorities and the project’s dependence on future appropriations which make such projections meaningless at this time.” While ADEC understands the need to readjust priorities given new information, it is important to establish reasonable long-term schedules for needed work based upon current information. Given that the TPA is premised upon NOAA’s obligation to seek adequate future appropriations to accomplish needed work under the agreement (section 66) it is important that NOAA develop for ADEC’s concurrence a long-term schedule. As you know under section 81, we can adjust the long-term schedule in light of the results of future site investigation and clean-up work. Accordingly, ADEC requests that NOAA develop a long-term schedule for the work contemplated by the TPA given current information at the sites. |
Louis Howard |
| 10/31/2001 |
Update or Other Action |
During the 2000 and 2001 field seasons, an estimated 5,000 yd3 of PCS were thermally remediated each year by Tanaq using the NOAA ETC System, for a total of 10,000 yd3 (truck volume). At the beginning of 2001, an estimated 1,200 cubic yards (truck volume) of PCS remained in the stockpile. In 2001, NOAA contracted the St. George Chadux Corporation (Chadux), the Small Business Administration 8(a) subsidiary of Tanaq, to continue environmental cleanup activities on island. |
Louis Howard |
| 12/31/2001 |
Long Term Monitoring Established |
During 2001 and 2003, groundwater wells were installed in the City oceanfront area to support water quality monitoring, water level logging and flow gradient modeling, plume size determination, and product removal/groundwater treatment. Groundwater flow in the area of the Inactive Gas Station is to the west-southwest. Four quarters of sampling found light no-aqueous phase liquids (LNAPL) in wells TPA1-MW1, TPA8-MW-12, with a thickness of 1 foot above groundwater. A thin layer of LNAPL in well TPA1-MW4 inhibited sampling of this well. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
Additionally, DRO, GRO, and benzene in well TPA1-MW-3 and DRO and GRO in well TPA1-MW-2 were detected above ADEC Table C cleanup levels. DRO, GRO and benzene were not detected in down gradient well VIL-MW3. Spills and leakage from the Inactive Gas Station may have contributed to groundwater contamination in the City's waterfront area, however, the LNAPL plumes are centered at and most likely attributable to historic operations at TPA Site 1 (Former Diesel Tank Farm) and TPA Site 8 (Active Power Plant). |
Louis Howard |
| 12/31/2001 |
Update or Other Action |
In August and October 2001, Tetra Tech EM, Inc. (TTEMI) conducted site characterization sampling of TPA 3. DRO was detected above ADEC method two cleanup levels of 250 mg/kg (940 mg/kg and 4,400 mg/kg at 2-4 ft. bgs). These samples were from the same vicinity as the Polarconsult excavation. This area is adjacent to the active municipal sewer system and thus, NOAA considered further excavation of this area not practicable. |
Louis Howard |
| 2/11/2002 |
Update or Other Action |
Staff has reviewed and commented on the revised Site Activity Schedule for FY 2002 and projected future work beyond 2002 during a meeting with NOAA on February 5, 2002.
The submittals are being accepted by the ADEC under the Modification clause of the Pribilof Islands Environmental Restoration Agreement section 82 page 20. “Modifications, extensions, and/or actions taken pursuant to 6-13 (Review and Comment on Documents); 14-17 (Subsequent Modification); 41 (Briefings and Progress Reports); 50-53 (Sampling and Data/Document Availability); 63-65 (Extensions/Force Majeure) and Attachment B* may be effected by the agreement of the Project Managers. Any modification approved orally under this Paragraph must be reduced to writing within ten (10) Days and signed by both Project Managers. The ADEC’s approval does not preclude nor eliminate the annual review required by the ADEC and NOAA to update the deadlines in Attachment B based on preliminary assessments, site investigations, or other information obtained during the preceding field season.
*Except as otherwise agreed to by the Parties, NOAA shall prepare the documents identified in Attachment B to this Agreement by the corresponding deadlines established in Attachment B. Attachment B shall be reviewed and updated annually by the Parties, based on the site assessment and other information obtained during the course of the preceding year, and may be modified at any time in accordance with Paragraphs 81- 82. Annual review of Attachment B shall commence in January of each year and shall be completed by March 31 of the same year.
The ADEC also wishes to point out to NOAA that the TPA states: “NOAA shall submit to the ADEC (at) a minimum of sixty-five (65) Days prior to the start of field work or construction at any source area, all draft final work plans for field work, site assessments or remedial actions (both interim and final at such source area(s). Site Assessment and Remedial Action draft reports must be submitted to the ADEC within 120 Days after completion of field work.” For example, work that NOAA has scheduled to begin on May 15 would require work plans to be submitted no later than March 11, 2002 for ADEC review and comment.
With respect to the sites that NOAA has identified as formerly used defense sites (FUDS) sites, the ADEC does not have sufficient information at this time to make a determination of whether the schedule for these sites should be extended under the force Majeure provisions of section 66 of the TPA because of a lack of funding to NOAA due to the appropriation restrictions in Public Law 106-52 (Pribilof Island Transition Act) Sec. 107(f)(2).
In order for the ADEC to make this determination, ADEC requests that NOAA submit reports and associated supporting data from the investigation and other work performed at the TPA sites or the portions of those sites NOAA is identifying as FUDS sites. The ADEC requests that NOAA also submit maps and location descriptions of those TPA sites or portions thereof that NOAA believes are FUDS sites. The ADEC will then seek a determination by the U.S. Army Corps of Engineers whether it concurs that theses are FUDS sites and whether the Corps will reopen the sites based upon the new information prepared by NOAA.
NOAA has not fully funded the work necessary to meet all of the conditions of the TPA. Item 66 of the TPA states: It is the expectation of the Parties to this Agreement that all obligations of NOAA arising under this Agreement will be fully funded. NOAA shall request, through the normal Department of Commerce budget process, all funds and/or authorizations necessary to meet the conditions of this Agreement,
1) If sufficient funds are not appropriated by Congress as requested and existing funds are not available to achieve compliance with the schedules provided in this Agreement, and NOAA reports the lack of funds in accordance with Paragraph 67, then the compliance schedule shall be revised as necessary.
NOAA has submitted the necessary revised schedules for Attachment B based on available funding.
2) If the Congressional budget appropriation available for the activities to be performed under this Agreement is lower than the budget request for such activities, and NOAA cannot mitigate the impact on its performance under this Agreement by seeking supplemental appropriations, NOAA may elect to reduce allocations for specific field projects based on the priorities identified by the Community Advisory Committee established under Paragraph 56 of this Agreement, and, if the Community Advisory Committee members agree, may reallocate funds from one island to another. |
Louis Howard |
| 10/31/2002 |
Update or Other Action |
During the 2002 field season, an estimated 1,500 cubic yards of PCS (truck volume), including the remainder of the 1997 PCS and 300 cubic yards of PCS excavated that year, were treated in the ETC System. In 2002, an estimated 3,275 cubic yards of PCS was added to the stockpile from NOAA corrective action sites on St. George Island.
In September 2002, coal was excavated from the Coal Subsite of the Open Pit Site (TPA Site No. 6) and stockpiled on the western extremis of the PCS stockpile liner. On the 19th of September, the coal pile was surveyed with the NOAA, survey grade Trimble GPS Total Station 5700 differential global positioning system (DGPS), and the volume calculated to be 70 cubic yards. |
Louis Howard |
| 3/10/2003 |
Document, Report, or Work plan Review - other |
Staff received and commented on the Draft Site Characterization Report for TPA Sites 1, 2, and 3 for St. George Island on March 14, 2003.
4.3.2.7 Comparison of Metals with Background Levels TPA Site 1 Pages 38 and 39 Site 2 Pages 43 and 44 and Site 3 Pages 48 and 49
The Department agrees that arsenic and chromium have met the applicable cleanup standards.
6.2 Evaluation of Corrective Action for Groundwater Pages 68 and 69
At Two Party Agreement (TPA) site no. 1, the diesel range organics (DRO) concentrations at 4,800 ug/L in groundwater would not exceed 15,000 ug/L ten times (10X) rule concentration, should NOAA successfully apply for and be granted this alternate cleanup level.
8.0 Recommendations Pages 70 and 71
The Department concurs with the recommendations presented in this section. However, if NOAA applies for and obtains a 10X rule determination, it need only consider implementing the option of a pump and treat system using an oil-water separator for benzene at TPA 1. |
Louis Howard |
| 10/31/2003 |
Update or Other Action |
In 2003, the ETC System was disassembled and initially prepared for off-island shipment. By the end of the 2003 field season, an estimated 5,400 cubic yards of PCS was added to the stockpile from PCS removal actions on island, increasing the stockpile volume to 8,700 cubic yards, estimated as loose truck volume (as opposed to compacted in-situ volume). |
Louis Howard |
| 5/3/2004 |
Update or Other Action |
Staff received and reviewed NOAA's request for Approval for Continued Storage, Petroleum Contaminated Soil (PCS) Long-Term Stockpile, St. George Island, Alaska Two Party Agreement Site No. 22-6 (TPA 22-6) received on April 29, 2004 via electronic mail. Staff concurred with NOAA’s plans to cover the stockpile at the end of the 2004 field season. Total volume of the stockpile is not to exceed ten-thousand (10,000) cubic yards as a long-term stockpile site. Be aware that NOAA’s definition of the term “long-term” storage does not meet the regulatory definition of “long-term storage”. 18 AAC 75.370 Soil Storage and Disposal Table D refers to long term storage as one-hundred eighty (180) days to two (2) years.
Those stockpiles which are used for storage longer than two (2) years without treatment may require a solid waste permit review under 18 AAC 60 Solid Waste regulations. ADEC's approval is granted with the understanding that NOAA will provide a work plan addressing the stockpile’s ultimate disposition for ADEC review and comment by January 31, 2005. Without a work plan being submitted by this date, ADEC will require NOAA to apply for a solid waste permit for a monofill from the Solid Waste Program. |
Louis Howard |
| 10/31/2004 |
Update or Other Action |
By Spring 2004, this PCS had been compacted by both natural settlement and bulldozer operations over a period of 1 to 1-3/4 years. Consequently, in May 2004, NOAA surveyed the stockpile with the DGPS and calculated a stockpile volume of 6,100 cubic yards, an 18% volume reduction from the original truck volumes.
Prior to the start of the 2004 field season, NOAA requested and received ADEC approval for continued PCS storage at the site. NOAA also completed characterization sampling and analysis of the existing stockpile, under a plan approved by ADEC.
The resultant fixed laboratory data was used in the contaminant fate and transport model for proposed landspreading of PCS at the new St. George landfill submitted by NOAA, and with which ADEC concurred.
During the 2004 field season, an estimated 1,230 cubic yards of PCS (truck volume) was added from excavation activities at the Old Power Plant Site (TPA Site No. 9), bringing the total volume at the end of 2004 up to 7,330 cubic yards. NOAA had this additional PCS characterized and sample results summarized in a report. |
Louis Howard |
| 3/3/2005 |
Update or Other Action |
In winter 2005, NOAA requested and received ADEC approval to continue PCS storage at this site while NOAA completed this Site Closure Plan. NOAA's request "Request for Extension to Permit for Long-Term Petroleum-Contaminated Soil Stockpile Location March 3, 2005"; however it is now designated NOAA site 32.
Consistent with 18 AAC 75.365 (for offsite or portable treatment facilities), now that incineration operations are complete, NOAA is required to clean up and remediate any potential environmental pollution remaining at the site and restore this federal property to a good, clean, and level condition. |
Louis Howard |
| 7/6/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Site Closure Plan for the NOAA long-term Petroleum Contaminated Soil Stockpile Site.
The site closure work will follow the below listed general approach. The use of the words “site soil” means soils other than stockpiled PCS and sand bedding material, and includes the original naturally occurring in-situ soils and the scoria used to build the site in 1997.
•Removal of the 15,000 gallon steel AST and miscellaneous surface debris.
•Culling of debris, liner fragments and boulders from the PCS stockpile.
•Relocation of PCS and the coal pile from the stockpile to the new St. George landfill.
•Relocation of sand bedding material from the site to the new St. George landfill.
•Characterization sampling and analysis of the sand bedding material stockpile at the new St. George landfill.
•Removal of the metal sump and buried drainage culvert.
•Removal of the liner from the site.
•Excavation of site soils and relocation to the new St. George landfill.
•TLC field screening and confirmation soil sampling following excavation under the footprints of the PCS stockpile liner, ETC Operations area, and in the general area about the footprints.
•Confirmation sampling at both the vehicular ingress and egress points for the site.
•Site restoration.
•Survey and location by DGPS of all sample points, excavations, final disposal areas, characterized stockpile(s) and site restoration features.
•Preparation of debris and IDW for final disposition. |
Louis Howard |
| 7/25/2005 |
Cleanup Complete Determination Issued |
All corrective action has been completed to the maximum extent practicable and groundwater will be monitored as required since it remains above Table C values at this site. The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required: 1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1; 2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone; 3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and
4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. |
Louis Howard |
| 7/25/2005 |
Institutional Control Record Established |
In the event that the remaining contaminated soil becomes accessible by the removal of the soil located in the vicinity of the Inactive Gasoline Station TPA 3, the land owner and/or operator will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site requires approval from the Department in accordance with 18 AAC 75.325(i).
|
Louis Howard |
| 8/5/2008 |
Update or Other Action |
Notice of Environmental Cleanup and residual soil contamination at TPA Site no. 3. Pursuant to 18 AAC 75.375, the St. George Tanaq Corporation as the owner, and the U.S. Department of
Commerce/National Oceanic and Atmospheric Administration (NOAA), as the operator of the subject property hereby provide public notice that the property on the west side of the Tanaq Corporation Shop in the City of St. George, St George Island, Alaska 99591 is contaminated with petroleum products. More specifically, the property is described as follows:
Tract 43
Section 29, Township 41 South, Range 129 West, of the Seward Meridian, Alaska.
56° 36' 12.27" North Latitude, 169° 32' 49.68" West Longitude
This property, hereafter referred to as Site 3, has been subject to petroleum contaminated soil and groundwater from a discharge or release and subsequent cleanup regulated under 18 AAC 75, Article 3 as amended December 2006. Adequate soil cover needs to be maintained over the residual petroleum contaminated soil. If contaminated soil is exposed in the future, it must be
managed in accordance with laws applicable at that time.
ADEC determined, in accordance with 18 AAC 75 .325(f)(1), that Site 3 cleanup has been performed to the maximum extent practicable even though residual petroleum contaminated soil remained on the property (NOAA 2005a). ADEC granted a conditional closure, in part subject to this institutional control (deed notice), and confirmed that no further remedial action was required at the site unless new information becomes available that indicates to ADEC that the site may pose an unacceptable risk to human health, safety, welfare or the environment (NOAA
2005a).
Grantor:U.S. Bureau of Land Management
Grantee: St. George Tanaq Corporation, 4141 B Street, Suite 301, Anchorage, AK 99503
Recording District: Aleutian Islands
In the event that information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator is required under 18 AAC 75.300 to notifY ADEC and evaluate the environmental status of the contamination in accordance with applicable laws and regulations. Further site characterization and cleanup may be necessary under 18 AAC 75.325-.390 and 18 AAC 78.600. Also, any transport, treatment, or disposal of any potentially contaminated soil or water from the site or use of the groundwater at or near the contaminated area requires notification to and approval from the Department in accordance with AAC 75.370(b) and 18 AAC 78.600(h).
This notice remains in effect until a written determination from ADEC is recorded that states that soil at the site has been shown to meet the most stringent soil cleanup levels in Method Two of 18 AAC 75.341 (c) and that off-site transportation of soil is not a concern. |
Louis Howard |
| 9/20/2008 |
Update or Other Action |
The U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) Pribilof Project Office is responsible for site characterization and restoration on St. George Island, Alaska. Although NOAA has attempted to meet State of Alaska soil cleanup levels and has removed contaminated soil to the maximum extent practicable, residual contamination remains at some St. George Island sites. This report documents the nature of known or potential residual soil and groundwater contamination at NOAA-remediated sites and presents the rationale for leaving the contamination in place.
Of thirty-six (36) sites investigated and/or restored by NOAA at St. George Island, the following contaminants are known to remain or potentially may be present in soil and/or groundwater above applicable site cleanup levels:
• DRO at 20 sites.
• GRO at 5 sites.
• RRO at 3 sites.
• Benzene at 4 sites.
• Toluene at 3 sites.
• Ethylbenzene at 4 sites.
• Total xylenes at 4 sites.
• Perchloroethylene at 2 sites.
• Lead at 2 sites.
Contaminated soil may have been left in place at sites due to equipment limitations and/or the presence of utility lines, buildings, roads, and other structures. Additionally, NOAA was not obligated to excavate contaminated soil to address the inhalation and ingestion pathways fifteen (15) feet or greater below the ground surface, or at shallower depths when encountering the water table. Buried debris, such as municipal solid waste, also remains at some sites. In such locations, NOAA placed a soil cap over the debris according to State of Alaska requirements.
During 2006, NOAA initiated a long-term groundwater monitoring plan at St. George Island to monitor the migration and attenuation of groundwater contamination at NOAA Sites 35 and 36 and to gauge the effectiveness of soil remediation actions at NOAA Sites 1, 2, 3, 8 and 29. Other than acknowledging the presence of groundwater contamination at a site, groundwater is not addressed within the context of this report.
Inactive Gas Station, Site 3; TPA Site 3: A village fuel dispensing station was located along the oceanfront at Site 3 where two 1,000-gallon underground storage tanks (USTs) had been in service from the 1960s to the 1990s. The USTs were removed along with approximately 1,624 yd3 of contaminated soil in 1997 (PolarConsult 1997). Soils with contaminant concentrations above Method Two criteria were removed to the extent practicable; however, the excavation was constrained to the north by the City of St. George’s sewer station and vertically by basaltic bedrock.
At Site 3, soil contaminated with DRO in concentrations above the Method Two criterion for migration to groundwater remains just south of and parallel to the City sewer system at depths of 3.5 feet bgs and deeper. DRO, GRO, benzene, toluene, ethylbenzene and total xylene remain in concentrations above the Method Two criteria in the area beneath former the dispensing station at an equipment refusal/bedrock depth of approximately 14.1 feet bgs.
In 2001, environmental investigations found one discrete location at Site 3 where soil was contaminated with lead at a concentration of 612 milligrams/kilogram (mg/kg), which exceeded the Method Two residential criterion of 400 mg/kg (Tetra Tech 2003a). At a second discrete location, soil contaminated with perchloroethylene (PCE) was found at a concentration of 0.09 mg/kg (Tetra Tech 2003a), which exceeds the Method Two criterion of 0.03 mg/kg for migration to groundwater, but is well below the criteria for ingestion and inhalation (160 mg/kg and 80 mg/kg respectively).
In 2004, approximately 6 yd3 of lead-contaminated soil was excavated from the hot spot, placed in storage sacks, and subsequently shipped off-island. Excavation confirmation samples indicated that all lead contaminated soil had been removed (Tetra Tech 2005b). The sample location where PCE was found, two to four feet bgs, was located adjacent to the City sewer system; the ADEC-approved Site 3 corrective action plan (CAP) concluded that excavation of the PCE-contaminated soil was not practicable and would not be pursued (NOAA 2004a). |
Louis Howard |
| 9/26/2008 |
Update or Other Action |
Summary of Residual Soil Contamination and Buried Solid Wastes at NOAA Cleanup Sites on St. George Island. NOAA Site No. 3/TPA Site No. 3, Inactive Gas Station: contaminated soil, contaminated groundwater, UST/AST pipeline. Diesel range organics (DRO) contaminated soil remains just south of and parallel to the City sewer system at depths of 3.5 feet bgs and deeper. Perchloroethylene (PCE) remains in one location just south of the City sewer system from 2 to 4 feet bgs. DRO, GRO, benzene, toluene, ethylbenzene and total xylene remain in the area beneath the past location of the dispensing station at equipment refusal/bed rock depth of approximately 14 feet bgs. Groundwater is contaminated with DRO, GRO, and benzene in this area; see Site 36 [TPA 1b & 25-1b Oceanfront Sites Free Phase] below for information. Deed notice.
Site status as of September 26, 2008: NFRAP 07/25/2005. Propery Owners: City of St. George; St. George Tanaq Corporation (Tanaq). |
Louis Howard |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73154 name: auto-generated pm edit TPA 03 STG Inactive Gas Station |
Louis Howard |
